ClarkDietrich Conflict Minerals Policy

Dodd-Frank Section 1502 - Conflict Minerals

Background:

Congress passed the Dodd-Frank Wall Street Reform and Consumer Protection Act ("Dodd-Frank") in response to the housing market collapse and financial recession beginning in 2008. Section 1502 of "Dodd-Frank" identifies certain "Conflict Minerals" defined as Tantalum, Tin, Tungsten, and Gold, commonly referred to as "3TG" (the derivatives of Columbite-tantalite (Coltan), Cassiterite, Wolframite), originating from mines under control of armed militant groups accused of human rights violations operating in the eastern Democratic Republic of Congo ("DRC") and the adjoining countries. These countries include Angola, Burundi, Central African Republic, The Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda, and Zambia ("DRC Region"). This legislation outlines new reporting requirements and additional filings to be made by U.S. publicly traded companies with the U.S. Securities and Exchange Commission ("SEC") and disclosure must contain information about such Conflict Minerals originating from the DRC Region.

ClarkDietrich Building Systems Conflict Minerals Policy:

ClarkDietrich Building Systems is not a publicly traded company with the U.S. SEC and is therefore not required to report or disclose information on our supply chain regarding Conflict Minerals. However, ClarkDietrich supports ending the violence and human rights violations in the mining of Conflict Minerals and is committed to supporting the responsible sourcing of Conflict Minerals from the DRC region. Our Business Conduct Guide states that we promote honesty and integrity in all aspects of business and have the utmost respect for all individuals. Accordingly, ClarkDietrich has adopted a "Conflict Minerals Policy" and expects its suppliers to comply with this policy.

Currently ClarkDietrich does NOT purchase or sell any steel or metal products containing Conflict Minerals. The steel purchased to manufacture our cold-formed steel framing products meet the specifications of ASTM A1003, Table 2-Chemical Composition Heat and Product Analysis, Max %, which does not include any Conflict Minerals. This is substantiated by The Definitive Guide to Conflict Minerals Compliance for Manufacturers, published by MetalMiner, on page 12 of 13 where they state that “Steel – Contains no conflict minerals, including all common grades of HRC, CRC, plate, HDG, rebar, wire rod, etc.”

Suppliers Expectations:

Based on our policy listed above, ClarkDietrich Building Systems considers all of our suppliers as partners in compliance efforts with the Dodd-Frank reporting regulations. In order to verify compliance with the ClarkDietrich policy, it is necessary for all suppliers to complete ClarkDietrich’s online questionnaire entitled "Confirmation of Agreement with Conflict Minerals Policy” (link below). ClarkDietrich also expects that:

Suppliers will not include, in any products sold to ClarkDietrich, any Conflict Minerals mined in the DRC Region that fund armed conflict. If the supplier is initially unable to determine the source of the minerals in its products, it will make its best effort to determine the source as soon as possible.

ClarkDietrich Building Systems expects its supplier partners to promote an environment of respect for all individuals worldwide and to operate in a manner that imposes honor and integrity in all aspects of business. Only companies who comply with ClarkDietrich’s above stated policy will be considered for the supply of components or materials that are incorporated into any final product, manufactured or contracted to be manufactured, by ClarkDietrich.

As recommended by the OECD Due Diligence Guidance, ClarkDietrich Building Systems has established a grievance mechanism as a risk-awareness system for conflict minerals issues. Stakeholders can communicate directly and confidentially with our compliance officer at supply.chain@clarkdietrich.com.

For more information, please contact ClarkDietrich Building Systems at: